State Farm Corporate Headquarters 1 State Farm Plaza Bloomington, IL 61710-0001
December23, 2014 U.S. Department ofTransportation Docket Management System 1200 NewJerseyAve., SE West Building Ground Floor Room W12-140 Washington, D.C. 20590 

# &State**Farm~**

Re: Docket No. FAA-2014-0846; Summary Notice No. PE-2014-125 State Farm Mutual Automobile Insurance Company; Petition for Exemption Dear Sir or Madam: State Farm Mutual Automobile Insurance Company ("State Farm") submitsthis letterforthe FAA's consideration in connection with State Farm's petition under Section 333 ofthe FAA Modernization and Reform Act of2012 1for an exemption to allow operation of Unmanned Aircraft Systems ("UAS") to conduct roof inspections.2 Two commenters, the Air Line Pilots Association ("ALPA") and the National Agricultural Aviation Association ("NAM"), filed in opposition to State Farm's petition citing various concerns. This filing explains how State Farm's proposed operations, as detailed in the company's petition for exemption, will be conducted to ensure safetyto those on the ground and other aircraft. Area ofOperation. ALPA states that State Farm's petition does not define howthe area of operation will be limited or predetermined and does not offera meansto control the airspace or areas ofoperation. 3 To the contrary, State Farm's petition describesthe parameters ofthe area of operation-usewill occursolely over customers' property and under200 feet above ground level ("AGL").4 State Farm will use gee-fencing as the meansto control the area ofoperations.5 Indeed, atypical UAS flight for roof inspection would occur predominantly nearand around the structures ofthe property. Mitigation of Hazard to OtherAircraft. ALPA suggests that State Farm's petition does not ensurethatthe hazard ofother aircraft intruding on the operation is mitigated. 6 Both ALPA and NAM raise concerns about howthe UAS will "sense and avoid" otheraircraft. 7 State Farm's

2 FAA Modernization and Reform Act of2012, Pub Law No. 112-95. See Docket No. FAA-2014-0846; Summary Notice No. PE-2014-125. 3 Comments ofALPA, Docket No. FAA-2014-0846 at 1 (filed Dec. 3, 2014) ("ALPA Comments"). 4 State Farm Petition for Exemption, Docket No. FAA-2014-0846 at2, 3 (filed Oct. 15, 2014) ("State Farm Petition"). 5 State Farm Petition at 3. s ALPA Comments at 1. 7 ALPA Comments at 2; Comments ofNAAA, FAA Docket No. FAA-2014-0846 at 1-2 (filed Dec. 3, 2014) ("NAAA Comments"). Providing Insurance andFinancial Services Home Office, Bloomington, ILpetition explains that hazardsto other aircraft will be mitigated through avariety ofsafety measures.
• State Farm's UAS will only operate during daytime. 8

• UAS operations will always occurwithin the line ofsight ofthe UAS operator.9

• The operatorwill request a Noticeto Airmen ("NOT AM") not morethan 72 hours in advance but not less than 48 hours priorto UAS operations. 10

• State Farm will ensure safety to first responder aircraft and helicoptertraffic. Upon notification from aircraft controllers orthrough visual identification ofaircraft, State Farm will immediately suspend the UAS flight until the airspace is cleared. 11 State Farm notes that a typical UAS roof inspection would be conducted near and around property structures, areas unlikely be proximate to first responder aircraft and helicopters. These requirements, which the FAA approved in its grant ofthe motion picture and television operator petitions, 12will ensure that State Farm's use of UAS for roof inspections does not create a hazard to other users ofthe national airspace. Pilotand Observer Requirements. ALPA requests that both pilot and observer be able to maintain avisual observation ofboth the aircraft and the area ofoperation. 13 NAAA adds that the operator should be attending/monitoring the UAS at all times and that the observer must be present and able to communicatewith the operatorfrom the most minimal distance possible. 14 State Farm's petition statesthat the UAS must be operated in the visual line ofsight ofthe pilot at all times, and the Operations Manual notesthat the observer is responsible for keeping the vehicle in sight at all times. 15 The Petition also states thatthat the pilot and observer must be able to communicateverbally at all times. 16 Lost Signal Mitigations. ALPA's filing queries howthe UAS will safely land in the event ofa loss ofGPS. 17 State Farm's Operations Manual details howthe UAS will respond in such a situation. The UAS has safetyfeatures which attemptto reacquire the lost signal and will help

a State Farm Petition at 4. 9 State Farm Petition at2, 3, 6. NAAA's comments also specifically requestthat UAS operators be subjectto the requirementto maintain line-of-sight operations. NAAA Comments at 2. 10 State Farm Petition at 7. NAAA's comments also specifically requestthat UAS operators be subjectto this NOT AM requirement. NAAA Comments at2. 11 State Farm Petition at 8. 12 See, e.g. FAA, Grantof Exemption, Astraeus Aerial, FAA Docket No. FAA-2014-0352, Exemption No. 11062 (Sept. 25, 2014) ("Astraeus Grant"). 13 ALPA Comments at 1. 14 NAAAComments at2-3. 15 State Farm Petition at6; State Farm UAS Operations Manual, FAA Docket No. FAA-2014-0846, at 3-3(filed Oct. 15, 2014) ("Operations Manual"). 1s State Farm Petition at5. 11 ALPA Comments at2.

Providing Insurance andFinancial Services Home Office, Bloomington, ILthe UAS safely descend ifGPS is lost. 18 ALPA's filing also states that mitigations for spectrum interference, terrain, and obstacles should be developed. 19 State Farm's Operations Manual further describes safety features that will help maintain safe operations in the event of emergencies such as power loss, loss ofcommunications, loss ofvideo link, airspace incursion from other aircraft, and software crashes. 2

# ° Forexample:
• Loss ofpowerto the propulsion systems will result in a controlled landing at an emergency decision site and the UAS will continue to operate with the communications link and flight controls;

• Ifa loss ofcommunications occurs, a communications strength indicator on the ground station will alert the operator, then the UAS will navigateto the home way point which is uploaded beforetakeoff. The UAS will continue to re-acquire link while it navigates through the landing procedure and loiter along atangential path to the touchdown spot;
• Ifa loss ofvideo link occurs, the manual has a checklist ofsystems to check and verify settings;
• In the event ofairspace incursion from another aircraft, the pilot and observer should directthe UAS to safe altitudes and locationsto maintain safe separation and continue to monitor incurring aircraftfordirection, speed, and altitude. Ifa collision appears eminent, the operator is instructed to manually down the vehicle;
• In the event ofa software crash, the UAS operatorwill immediatelyturn offthe comm box to ensurethat the UAS loses command and control and will begin to perform its loss ofcommunication procedure. 21 Hazard to Low-Level Pilots. NAAA notes its concern that State Farm's UAS will present a hazard to low-level pilots. 22 State Farm's proposed roof inspection operation will occur at a maximum ceiling of200 feet AGL and solely over policyholders' property. 23 The FAA and other aircraftwill have advance notice ofthe flight area due to the NOT AM. Further, as noted above, UAS roof inspection operations will occur predominantly nearand around structures. It is therefore highly unlikelythat State Farm's use of UAS for roof inspection will be proximate to low-level aircraft conducting aerial application of pesticides. NAAA also suggests that if an agricultural or othertype of low-flying aircraft is within two miles, the UAS operator procedure should be to immediately ground the UAS as soon as practicable. 24 State Farm's petition requires the UAS to yield right ofway to all manned aircraft, and to ensure safety to first responder aircraft and helicoptertraffic.25 Further, upon notification from manned

16 Operations Manual at 9-1 - 9-2. 19 ALPA Comments at2. 20 Operations Manual at 9-1 - 9-5. 21 /d. 22 NAAA Comments at 1. 23 State Farm Petition at2, 3. 24 NAAA Comments at2. 25 State Farm Petition at 8.

Providing Insurance andFinancial Services Home Office, Bloomington, ILaircraft controllers orthrough visual identification of manned aircraft, State Farm will immediately suspend the UAS flight until the airspace is cleared. 26 Finally, NAAAstatesthat UAS conducting low-level aerial application work must comply with 14 C.F.R. Part 137.27 This proposal is not applicable to State Farm's UAS, which will not be conducting low-level aerial application work. Airworthiness Certificate. ALPA opposes what it views as State Farm's attemptto avoid certifying the airworthiness of its UAS. 28 NAAA likewise proposesthat the UAS be required to have an airworthiness certificate. 29 State Farm notesthatthe requirementto have an airworthiness certificate was waived in the FAA's previous Section 333 grantsto the motion picture and television operators. 30 The State Farm petition merits the same exemption dueto the UAS safety features and its size, weight, speed, and operating area. Pilots License and Medical Certificate. ALPA and NAAA's comments both state that the UAS pilot should hold at least a current FAA commercial pilot certificate and a current 2nd class FAA medical certificate. 31 The FAA addressed this issue in its previous Section 333 grants. The FAA analyzed the UAS's separation from manned aircraft operations, the current aeronautical knowledge requirements for a private pilot compared to a commercial pilot, and the specific airmanship skills required for operation ofa UAS. 32Given these considerations, the FAAfound that its safety objectives would be met by only requiring a pilotto possess a private pilot certificate and at least athird-class medical certificate. 33 Accordingly, the State Farm petition provides that pilots undertaking roof inspectionswill hold at least a private pilot certificate and a third class medical certificate. 34 Minimum Safe Altitudes. ALPA's position is that all aircraft in the national airspace system ("NAS") must maintain minimum safe altitudes as required in 14 C.F.R. 

### § 91.113. 35 As noted above, State Farm's UAS will operate at no more than 200feet above ground level and will be operated in a defined area.36 The FAA previously granted an exemption to Section 91.119(c) on minimum safe altitudes in the motion picture and television operatorgrants.37 State Farm's UAS operations will occur at safe altitudes with respectto manned aircraft.

26 27 26 29 30 31 32 33 34 35 36 37 /d. NAAA Comments at 3. ALPA Comments at2. NAAAComments at2. See, e.g. Astraeus Grantat 14. ALPA Comments at2; NAAA Comments at2. See, e.g. Astraeus Grantat 17-18. /d. at25. State Farm Petition at5. ALPA Comments at2. State Farm Petition at 6. See, e.g. Astraeus Grant at20.

Providing Insurance andFinancialServices Home Office, Bloomington, ILAltimeter Settings. ALPA raises the concern that, dueto the lack of a barometric altimeter on the UAS, processes or mitigationsfor system and equipmentfailures must be in place. 38 The FAA's grants to the motion picture and television operators permitted use of a GPS altitude readout instead ofa barometric altimeter, finding thatthis alternative means of compliance with the FAA's rules would not adversely affect safety. 39 State Farm's petition notes that the UAS may have a GPS altitude readout and the Operations Manual details the failsafe systems and safety features ofthe UAS.40 Maintenance. ALPA states that FAAcertified professionals should perform all inspections and owner/operators should keep records verifying certain maintenance is in compliance.41 NAAA also suggests requiring that the UAS be properly maintained.42 State Farm's petition notesthat the company will institute a rigorous maintenance program and the operator will develop procedures to document and maintain a record of UAS maintenance.43 State Farm requires that all maintenance and alterations be properly documented in the aircraft records.44 Further, operators will develop UAS technician qualification criteria, which will be added to the Operations Manual.45 State Farm's commitments promote safe, regular maintenance ofthe UAS. UAS Markings. NAAA believes that UAS should be painted in colors to make them readily distinguishable from the background and that the UAS and ground vehicle should have strobe lighting.46 State Farm's UAS operations will only occurduring daytime, eliminating the need for special color painting orstrobe lighting.47 NAAAfurther suggests that the UAS should have a registered N-numberon an indestructible and unmovable plate attached to the UAS.48 State Farm's petition already includes the commitmentthat the UAS will have markings identifying the serial number and N-numberas large as practicable.49 FAA Oversight. As a final matter, ALPA notes its concern that the use ofwaiver requests could tax the FAA's resources and thatthe request is not for a single specific operation or location, increasing the FAA's oversighttask.

# 5° First, the Section 333 exemption process is the interim policy that the FAA has chosen to establish until the small UAS rule is adopted. The FAA has noted that it is anticipated that this activity will result in significant economic benefits,

38 39 40 41 42 43 44 45 46 47 48 49 50 ALPA Comments at2. See, e.g. Astraeus Grant at21. State Farm Petition at 8; see e.g. Operations Manual at 9-1 -9-5. ALPA Comments at3. NAAA Comments at3. State Farm Petition at 9. State Farm Petition at 10. /d. NAAA Comments at 2. State Farm Petition at4. NAAA Comments at 3. State Farm Petition at4. ALPA Comments at3.

Providing Insurance andFinancial Services Home Office, Bloomington, ILand the FAAAdministrator has identifiedthis activity as a high priority project.51 The FAA is moving forward carefully with granting these requests and there is no reason to doubtthe agency's abilityto oversee the operations 

### it permits. Second, State Farm's proposed operations will occur overcustomer property in defined and pre-determined areas, which should simplify the FAA's oversight. In conclusion, State Farm's petition to use UAS for roof inspections addressesthe safety concerns voiced by ALPA and NAAA. The petition is supported by the Small UAV Coalition.52 State Farm respectfully requests that the FAA move expeditiously to grantthe State Farm petition.
Sincerely,

# ~7l~ Todd Binion, CPCU®, CLU® Innovation Manager State Farm Mutual Automobile Insurance Company 309-735-8633 todd.binion.hkoO@statefarm.com

51 FAA, Section 333, available athttps://www.faa.gov/uas/legislative programs/section 333/. 52 Comments ofSmall UAV Coalition, Docket No. FAA-2014-0846 (filed Dec. 3, 2014).

Providing Insurance andFinancial Services Home Office, Bloomington, IL